I am here as a representative of the American College of Laboratory Animal Medicine (ACLAM). The key phrase here is “as a representative. ” I am neither an elected officer nor a current member of the board, so I do not represent the leadership or membership of ACLAM. I am completing a 4-year term as one of the original members of the ACLAM Foundation. The Foundation's goal is to increase the body of knowledge in laboratory animal medicine and science by raising money to support research that accomplishes this goal. I also currently serve as ACLAM 's nominee on the 1999 American Veterinary Medical Association's Panel on Euthanasia, and I previously served on the 1993 Panel. It is because of my current involvement on this panel that Dr. Margaret Landi, ACLAM President, called and asked if I could attend this meeting in her absence.

The USDA Animal Care Policies are in reality de facto regulations. They are interpretive rules that, although not legally binding, leave us only a challenge in court if we do not agree. There is no mandated public comment period with a subsequent response to those comments as part of publishing the Final Rule. As such, the regulated community, the scientific community, has no mandated opportunity to provide their input or to learn how their input was considered in developing the Final Rule. The policies in effect regulate a scientific activity, without having had the mandated participation of the regulated community in their development. Any changes to existing definitions, addition of new definitions, and revisions to the annual reporting process should take place as changes to the Regulations with publication in the Federal Register, a mandated public comment period, and publication of the Final Rule with USDA commenting on why it accepted or rejected those comments.

Why would I ask for more regulations? I am not asking for more regulations, I am asking for a process that gives the scientific community a full opportunity to address the available scientific information on pain and distress and its application in clinical practice. I believe that available scientific information strongly speaks for not adding additional language to the regulations/policies, and I believe that a formal public comment period will make this fact abundantly clear.

Pain and distress are responses to environmental and internal events that affect the well-being of those that experience them. Adequate definitions/ explanations can be found in the literature. Such definitions should be incorporated into the policy and procedure documents of every IACUC in the country. They do not need to be redefined in regulations and policies.

Pain and distress are medical problems that first require detection, then determination of a cause (the diagnosis), and then alleviation (the treatment). Pain and distress are medical care issues that must be dealt with on a case-by-case